Self Guided Walking Holidays in
South West England and Wales
+44 (0) 1208 871066
Detailed Privacy Policy
Detailed Privacy Policy
General Data Protection Regulations Data Privacy Notice
This is the privacy notice of Encounter Walking Holidays Ltd
We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
1. Who we are and Important Information
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you request a quote or make a booking with us.
This website is not intended for children and we do not knowingly collect data relating to children unless they are on holiday with their guardian when we will collect name, age, dietary requirements and any relevant medical issues for the holiday activity only.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Data controller(s)
Encounter Walking Holidays Ltd. is the controller and responsible for your personal data (collectively referred to as "Encounter Walking Holidays Ltd.", "we", "us" or "our" in this privacy notice). Our contact details are 12 Cott Road, Lostwithiel, Cornwall PL22 0ET Telephone: 01208 - 871066. Email: info@encounterwalkingholidays.com. For all data matters contact the Office Supervisor by email at info@encounterwalkingholidays.com.
Third-party links outside of our control
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The Personal Data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
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Identity Data includes your full name, nationality and age
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Contact Data includes your billing address, delivery address, email address, contact telephone numbers
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Booking Specific Data Dietary requirements and any medical or disability information you feel is relevant to your Holiday
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Financial Data when requesting us to take a card payment from you and bank details if we are making a refund to you.
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Technical Data includes IP address/browser type and version/location/operating system and platform/other technology on the devices you use to access this website.
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Usage Data includes information about how you use our website, products and services
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Take a look at this website for more information on cookies: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage?csw=1
We collect only one Special Category of Personal Data about you and this is any medical or disability information you feel is relevant to your Holiday. We do not collect any details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect your personal data to create a contract with you and you fail to provide that data when requested, we may not be able to perform the contract with you to book your walking holiday - in this case, we may not be able to continue with your booking but we will notify you if this is the case at the time.
3. How we Collect your Personal Data
We use different methods to collect data from and about you including through:
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Directly. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
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Request a quote on our website or by telephone
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Make a booking with us
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Make a telephone payment with us
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Request marketing to be sent to you
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Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
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Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
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Technical Data from the following parties:
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Analytics providers such as Google based outside the EU;
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Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Worldpay based inside and outside the EU.
4. How we use your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting the Office Supervisor, Encounter Walking Holidays Ltd, 12 Cott Road, Lostwithiel, Cornwall. PL22 0ET – Email: info@encounterwalkingholidays.com
Purposes for which we will use your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact the Office Supervisor, Encounter Walking Holidays Ltd, 12 Cott Road, Lostwithiel, Cornwall. PL22 0ET – Email: info@encounterwalkingholidays.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.
You will receive marketing communications from us if you have requested information from us, asked to join our marketing mailing list or purchased goods or services from us.
Third-party marketing
We do not pass any details to any other company for third party marketing
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of requesting a quote or booking a holiday with us.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the Office Supervisor, Encounter Walking Holidays Ltd, 12 Cott Road, Lostwithiel, Cornwall, PL22 0ET – Email: info@encounterwalkingholidays.com
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Who we share your Personal Data with
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
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External Third Parties - For Example:
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Providers acting as processors based in the United Kingdom who provide IT and system administration services.
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Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
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HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
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Specific third parties such as luggage transfer providers, taxi transfer providers and accommodation providers.
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Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Purpose / Activity
Type of Data
Lawful basis for processing including basis of legitimate interest
To provide you with a quote for a holiday
(a) Identity
(b) Contact
Necessary for our legitimate interests
(to provide you with a quote for a holiday)
To book your holiday
(a) Identity
(b) Contact
(c) Names of other walkers
(d) Medical
Performance of a contract with you
Necessary for our legitimate interests (to book your holiday)
For Medical Data - the data subject has given explicit consent to the processing of those personal data for one or more specified purposes (to book your holiday)
To invoice you for your holiday
(a) Identity
(b) Contact
(c) Financial
Performance of a contract with you
Comply with a legal or regulatory obligation
Necessary for our legitmate interests (to recover payments due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing &
Communications
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services and to provide our customers with information on our products)
To administer and protect our business and this website
(including troubleshooting, data analysis, testing,
system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website,
products/services, marketing, customer relationships
and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
6. International Transfers
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Examples of these third parties are: Intuit – Quickbooks, Worldpay and Google Analytics.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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It is necessary to keep some information for 6 years. This is for accounting and legal purposes only. This will be the information that is shown on your invoice.
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No later than one year after your holiday, we will delete all information except you name and address and details of walks that you have booked with us. This information will be retained for three years for the purpose of ensuring that we provide the correct product for any further holiday bookings within that period
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your Legal Rights
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
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The right to be informed - the right to allow individuals to obtain information on how and why we hold and process their personal data
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The right of access - the right to request a copy of the personal data which we hold about you;
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The right to rectification - the right to request that we correct any personal data if it is found to be inaccurate or out of date;
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The right to erasure - the right to request your personal data is erased where it is no longer necessary to retain such data;
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The right to object to processing - the right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
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The right to data portability - the right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. (where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
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The right to restriction of processing - the right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
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Rights in relation to automated decision making and profiling - the right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact the Office Supervisor, Encounter Walking Holidays Ltd, 12 Cott Road, Lostwithiel, Cornwall. PL22 0ET
Email: info@encounterwalkingholidays.com
No fee required – with some exceptions
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Changes to this notice and your duty to inform us of changes
This version was last updated on 17th May 2018
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
11. Queries, requests or concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please contact the Office Supervisor, Encounter Walking Holidays Ltd, 12 Cott Road, Lostwithiel, Cornwall. PL22 0ET – Email: info@encounterwalkingholidays.com
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.